Alamerica Bank and its affiliates pledge to protect the privacy of our
customers’ information. As part of this commitment we have adopted the following
privacy principles and have implemented them at all levels of our organization.

INFORMATION WE COLLECT
We collect nonpublic personal information about you from the following sources:

Information we receive from you on applications or other forms;

Information about your transactions with us, our affiliates, or others;
and

Information we receive from a consumer reporting agency.

WE RECOGNIZE OUR CUSTOMERS’ EXPECTATION OF PRIVACY
We understand that our customers expect personal and financial affairs to be
held in the strictest confidence. The Alamerica Bank customer has entrusted us
to protect their privacy and to safeguard their personal information. We take
this responsibility seriously and have designed policies and procedures to
prevent misuse of this information.

INFORMATION WE DISCLOSE ABOUT YOU
We do not disclose any nonpublic personal information about our customers or
former customers to anyone outside of our organization, except as permitted by
law. As permitted by law, we may sometimes hire a vendor or service company to
prepare your account statements or to provide support for one or more of your
products or services.

WHY WE COLLECT, RETAIN, AND USE CUSTOMER INFORMATION
We collect, retain, and use information about our customers only where we
believe it will help administer our business or provide products, services, and
other opportunities. If we collect information about our customers, we will do
so only for a specific business purpose; and if requested, we will tell the
customer why we are collecting the information. Some of the reasons we use
customer information are the following: to protect and administer customer
records, accounts, and funds; to comply with certain laws and regulations; to
help us design and improve our products and services; and to better understand
the customers financial needs.

WE LIMIT EMPLOYEE ACCESS TO YOUR INFORMATION
Access to personally identifiable information about a customer is limited to
those employees who have a specific business reason to know such information.
Our employees are educated and trained on the importance of confidentiality and
privacy of customer information. Appropriate disciplinary action is taken if
this Policy or procedures relating to this Policy are not adhered to.

SECURITY PROCEDURES PROTECT CUSTOMER INFORMATION
We establish and maintain security procedures designed to help prevent
unauthorized access to customer private, confidential information. We also
update and test our computers, hardware, software, and other technology to
assure the integrity and security of our information systems.

WE RESTRICT DISCLOSURE OF ACCOUNT INFORMATION
We do not reveal specific information about customer accounts or other
personally identifiable data to parties outside our organization unless it is
under the following circumstances: a customer requests or authorizes disclosure;
the information is provided to help complete a transaction initiated by a
customer; the information is provided to a reputable credit bureau or similar
information reporting agency; or the disclosure is otherwise lawfully permitted
or required for the efficient and orderly operation of the Bank. We reserve the
right for future disclosure of nonpublic personal information with an affiliate.

WE WILL NOT SHARE CUSTOMER INFORMATION OUTSIDE OUR ORGANIZATION
We maintain procedures designed to protect customer confidential information.
Other than under the limited exceptions explained in the paragraph above and
permitted by law, it is our practice not to share confidential customer
information outside our organization. You do not need to request this
confidentiality – it is our standard practice.